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Letter 133 Reprogramming lines and waste treatment costs----- I am curious about what is involved in re-programming an automatic/semi-automatic line with clean technology in mind, i.e. reducing dragout and water consumption. It is difficult to convince operators that they can change the line without ruining their product. Also, I would be interested in where I might find information on the capital and operating costs for typical waste water treatment facilities at metal finishing shops. Alan Gagnet
Reprogramming a programmed hoist line is generally relatively easy, say one to two days work on average. But installing additional rinses, etc., can be a major (and sometimes impractical) undertaking. It is very difficult to give a canned answer to what is involved since it depends on how big the tanks are, how old, whether room exists to extend the line, etc. The EPA has published costs several times in the development documents used to support CFR 413, CFR 433, etc. The impacts of such changes and the associated costs have been severely underestimated by the EPA repeatedly, but they are pretty much universally available, and so a good starting point.
Dear Reader: please choose what you want to do.
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